EPA concerns with conditions at Tyndall Air Force base, which are detailed in the
attachment, include:
1. Significant contamination at Tyndall, which presents serious public health and
environmental risks.
2. The inadequacy of the Air Force's unilateral cleanup activities to protect public health
and the environment.
3. The Air Force's compliance violations, including its failure to comply with a final, valid
RCRA imminent and substantial endangerment order.
4. The insufficiency of a proposed state-based memorandum of agreement as a substitute for
lawful and accountable cleanup oversight.
5. Questions of financial management integrity at Tyndall.
6. Inaccurate Air Force representations about Tyndall, which may mislead the public.
Tyndall's disregard for its legal obligation to sign a CERCLA agreement or to comply
with its RCRA endangerment order means that those who work and live at the base, and others in
the surrounding area, may not be receiving the protections they are entitled to by law. As you
know, the EPA formally ended Tyndall FFA negotiations again on February 12, 2012, after
attempting once more to address the Air Force's concerns about the FFA.
While we have
attempted to negotiate in good faith many times over the past decade, we ended those
negotiations by concluding that the only FFA that the Air Force was willing to sign was one
inconsistent with federal law.
While EPA considers its next steps, we are providing this letter and its attachment as a
summary of our key concerns at this site for the record. We again urge the Air Force to meet its
legally-mandated cleanup obligations by complying with the RCRA order and by signing the
FFA provided by the Agency so that the activities at Tyndall are consistent with the law and are fully protective of human health and its environment.
Thoughts on this?
attachment, include:
1. Significant contamination at Tyndall, which presents serious public health and
environmental risks.
2. The inadequacy of the Air Force's unilateral cleanup activities to protect public health
and the environment.
3. The Air Force's compliance violations, including its failure to comply with a final, valid
RCRA imminent and substantial endangerment order.
4. The insufficiency of a proposed state-based memorandum of agreement as a substitute for
lawful and accountable cleanup oversight.
5. Questions of financial management integrity at Tyndall.
6. Inaccurate Air Force representations about Tyndall, which may mislead the public.
Tyndall's disregard for its legal obligation to sign a CERCLA agreement or to comply
with its RCRA endangerment order means that those who work and live at the base, and others in
the surrounding area, may not be receiving the protections they are entitled to by law. As you
know, the EPA formally ended Tyndall FFA negotiations again on February 12, 2012, after
attempting once more to address the Air Force's concerns about the FFA.
While we have
attempted to negotiate in good faith many times over the past decade, we ended those
negotiations by concluding that the only FFA that the Air Force was willing to sign was one
inconsistent with federal law.
While EPA considers its next steps, we are providing this letter and its attachment as a
summary of our key concerns at this site for the record. We again urge the Air Force to meet its
legally-mandated cleanup obligations by complying with the RCRA order and by signing the
FFA provided by the Agency so that the activities at Tyndall are consistent with the law and are fully protective of human health and its environment.
Thoughts on this?
